Brandt v. Solon Police Dept.

Citations

• 2022 Ohio 3732

Syllabus

public record R.C. 149.43 court of claims R.C. 2743.75 incident report attached incorporated contemporary initial R.C. 149.43(A)(2)(c) investigatory work product timeliness. Requester sought a police incident report. Respondent provided first one, and then the first nine, pages of the departmental incident report form and asserted the remainder was exempt from release as specific investigatory work product. The special master found that three additional pages of the report, and the videotaped victim interview, and photographs of evidence initially collected, and videotape initially obtained from the crime scene were not investigatory work product, but were all part of the initial incident report and must be disclosed. The special master further found that delay in disclosing the first nine pages of the report for fifteen days violated the requirement that an initial incident report be immediately released upon request.